Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective

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Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
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Becoming
climate aware
Mobilizing capital to help meet climate change goals:
an investor’s perspective

January 2020
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
A collective responsibility
    At UBS, we realize there is an urgent need to create a more cohesive and sustainable world. Climate
    change and poor economic inclusion are two major challenges towards this objective. They both have a
    clear framework outlining the extent of the challenge and required action: the Paris Agreement, and the
    United Nations’ Sustainable Development Goals (SDGs).

    For the past three years we’ve presented white papers to the WEF putting forward recommendations for
    ways in which private capital can achieve the 17 SDGs1, while also outlining our own actions and pledges
    in that regard. This year, our focus turns to the aims of the Paris Agreement and the orderly transition
    toward a lower-carbon world.

    The risks of climate change are an integral element of the duty of care that financial institutions have
    toward their clients and beneficiaries. That’s why this year’s paper focuses on one of the four global
    challenges to be discussed at Davos: ”How to address the urgent climate and environmental challenges
    that are harming our ecology and economy”.

    1   2017, Mobilizing private wealth for public good; 2018, Partnership for the goals; 2019, Awareness, simplification
        and contribution.

2
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
As with the SDGs, our aim is to be a leading financial provider in enabling investors to mobilize private and
institutional capital targeting climate change mitigation and adaptation while supporting the transition to
a low-carbon economy.

We’re calling for collaboration across the public sector, business and academia to enhance and deepen
the understanding of climate change. We invite the financial community to join us in developing solutions
and approaches that help investors make climate-smart investments and close the climate finance gap.
By partnering with industry bodies we seek to amplify our message: the time to act on climate is now.

Axel A. Weber                                                   Sergio P. Ermotti
Chairman of the Board of Directors                              Group Chief Executive Officer

                                                                                                                3
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
ubs.com/wef-2020
4
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
Authors
Kevin Arnold
Head of ICS Relationship Management,
UBS Investment Bank

Michael Baldinger
Head of Sustainable and Impact Investing,
UBS Asset Management

Phyllis Costanza
CEO UBS Optimus Foundation and
Head of UBS in Society

Mark Haefele
Global Chief Investment Officer,
UBS Global Wealth Management

Suni Harford
President,
UBS Asset Management

Special contribution
Huw van Steenis
Senior Adviser to the CEO and
Chair of the Sustainable Finance Committee,
UBS AG

Acknowledgements
Francis Condon, Gillian Dexter,
Christine Gugolz Kiefer
Sustainable and Impact Investing,
UBS Asset Management

                                              5
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
Contents                  7
UBS white paper for the   Introduction: The climate challenge
World Economic Forum
Annual Meeting 2020

                          10
                          The great divide
                          The climate finance gap: We explore the extent of the climate finance gap,
                          looking at what is being spent compared to what might actually be needed
                          to transition toward a lower-carbon future.

                          14
                          The barriers to investment
                          What climate challenges do investors face? Many investors want to account
                          for climate change factors in their portfolios, but at the moment that’s proving
                          difficult. We consider some of the challenges they face, from regulatory
                          frameworks to data imperfections.

                          30
                          The investors’ perspective
                          How are investors tackling climate change? While many are concerned with climate
                          change, the way they approach it can vary. As one of the world’s largest wealth
                          managers, we highlight their differing perspectives.

                          38
                          Are you climate aware?
                          How should investors respond? We suggest an investor-led framework for
                          addressing climate change. In this chapter, we outline a three step model that
                          we believe will help investors:
                          – Lower their investment exposure to climate risk
                          – Increase their investment exposure to climate-related innovation and solutions
                          – Align their investments to the requirements of a lower-carbon economy

                          56
                          Looking to the future
                          At UBS we’re working toward a climate-smart future. That’s why we’re continuing
                          to develop products and solutions which will help our clients to do the same.
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
Introduction

      The climate challenge
      Scientists warn that without urgent                  have risen 1.5 percent per year over the            the planet – including ours – will be
      action, by 2100 our world will be                    last decade. At current trends, we’re               catastrophic. The only solution is rapid,
      warmer than at any other time in                     looking at global heating of between                ambitious, transformative action by
      human history2. If we don’t act now,                 3.4 and 3.9 degrees Celsius by the end              all – governments, regions, cities,
      the result could be unprecedented and                of the century. The impact on all life on           businesses and civil society, all working
      widespread environmental, societal                                                                       together toward a common goal.”
      and economic disruption.

                                                          1.5%
                                                                                                               As we approach the fifth anniversary
      Speaking at the opening ceremony of                                                                      of the Paris Agreement, whether or
      COP 25 in December 2019, Antonio                                                                         not its targets can be met remains
      Guterres, Secretary General of the                                                                       unclear. Implementing current policies
      United Nations, said:                                                                                    and commitments suggests average
                                                                                                               temperatures will increase 3°C by the
      “According to the latest Emissions Gap                Greenhouse gas emissions                           end of this century. Do nothing and that
      Report from the UN Environment                        have risen 1.5 percent per year                    figure rises to 4°C. Humans have never
      Program, greenhouse gas emissions                     over the last decade                               lived in a world so warm.

      2   IPCC, 2018: Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global
          greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and
          efforts to eradicate poverty. Masson-Delmotte, et al.

                                                                                                                                                            7
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
Right now, a vast gulf exists                                                                         Our Chairman is a signatory to the
                                                                                                      European Financial Services Round

between the financial commitment                                                                      Table’s statement in support of a strong,
                                                                                                      ambitious response to climate change.
needed and the amount of                                                                              Also, our Group CEO is a member of the
                                                                                                      Alliance of CEO Climate Leaders, an
capital actually deployed.                                                                            informal network of CEOs convened
                                                                                                      by the World Economic Forum and
                                                                                                      committed to climate action. Our
But as scientific models improve, the              is committed to closing that climate               activities are underpinned by our climate
predicted outcomes are becoming                    finance gap. We believe we can do this             strategy, designed to support our clients
starker. Demands are growing for global            in two ways: through our own actions,              and our firm in preparing for an
warming to be held, not just at 2°C, but           and by developing products and services            increasingly carbon constrained world.
at 1.5°C by 21003.                                 that allow our clients to channel their
                                                   capital toward a climate-smart future.             Many clients share our climate
Achieving the Paris goals demands                                                                     commitment and want to use their
unprecedented levels of investment. But            In 1989, UBS was the first Swiss bank              capital in ways that can address a
right now, a vast gulf exists between the          to appoint an environmental officer to             warming world. This was a key finding
financial commitment needed and the                help focus on sustainability goals. Four           from a global survey of institutional
amount of capital actually deployed.               years later we were one of the earliest            asset owners that we conducted in
                                                   signatories to the United Nations                  20193. Most European investors said
Climate and the business                           Environment Programme (UNEP FI),                   that within five years environmental
community                                          and in 2016 we became a member                     factors could be playing a more
As one of the world’s largest managers             bank of the Task Force on Climate-                 important role in their investment
of private and institutional wealth, UBS           related Financial Disclosures (TCFD).              processes than financial factors.

3 IPCC, 2018: Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global
  greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and
  efforts to eradicate poverty. Masson-Delmotte, et al.
4 ESG: Do you or Don’t you? Responsible Investor and UBS Asset Management. June 2019.

8
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
Addressing the climate challenge                       We explore the underlying factors that               As we’ve shown in previous papers
Against that backdrop this paper                       we believe are hampering investors’                  submitted to the WEF6, we believe
addresses two key questions:                           ability to invest in a climate-smart way.            that at the heart of any solution to
                                                       In response, we propose a pragmatic,                 the climate crisis sits the need for
1. Why are current investment levels so                investor-led approach: one that goes                 collaboration. That is why we highlight
   far short of what we need to reach                  beyond the de-carbonization of                       our own collaborations as well as our
   the Paris Agreement goals? Many                     portfolios. One which recognizes that                recommendations, and call for ever
   investors want to direct their capital              waiting for data to be perfected or                  greater collective efforts from finance,
   toward a lower-carbon future. The                   legislation to be enacted only prolongs              business, academia and policymakers
   existence of that shortfall has been                the delay, and placing faith in the                  to secure the transition toward a
   widely discussed5, yet still it persists.           emergence of economic growth with                    lower-carbon world.
                                                       net negative CO2 emissions could prove
2. How can asset owners invest in a                    misplaced. This is an approach that                  In this white paper we’re recommending
   climate-smart future now? How do                    helps investors to be forward-thinking,              a response from investors. One that we
   they integrate known climate risks                  rather than rely solely on back-                     believe carries the potential to harness
   within their investment decisions,                  ward-looking data.                                   the power of private capital, at scale, to
   identify and invest in products and                                                                      more effectively tackle the challenges of
   solutions that can contribute to a                                                                       a warming world.
   lower-carbon world, while staying
   abreast of the regulatory and policy
   developments that could put the                     We explore the underlying factors
   world on track to meet the goals of
   the Paris Agreement? In short, how                  that we believe are hampering
   do they align their investments to a
   climate-smart future?                               investors’ ability to invest in a
                                                       climate-smart way.

5   https://climatepolicyinitiative.org/publication/ global-climate-finance-2019/
6   UBS: 2017, Mobilizing private wealth for public good; 2018, Partnership for the goals; 2019, Awareness, simplification and contribution.

                                                                                                                                                       9
Becoming climate aware - Mobilizing capital to help meet climate change goals: an investor's perspective
Icebergs have two main impacts on climate. Iceberg production affects the mass balance of the
parent ice sheets, and melting icebergs can influence both ocean structure and global sea level.

       10
The great
divide
The climate finance gap:
How much is enough?

What level of investment would be needed to meet the low-carbon transition?
There’s a wide range of answers. As the Climate Policy Initiative (CPI) noted, “While
there is no single estimate of the investment required to meet these goals [warming of
1.5°C], indicative, regional, and sectoral estimates show that the gap between existing
investment and what is needed represents an order of magnitude. … incremental
increases in climate finance flows will not deliver on these objectives”7.

7   https://climatepolicyinitiative.org/publication/ global-climate-finance-2019/

                                                                                        11
The great divide

Various bodies have estimated how much expenditure                             To fully de-carbonize, investments may need to be
different elements of the low-carbon transition might need.                    reallocated on an unprecedented scale
                                                                               Across 2017 and 2018, total climate finance averaged just
1. Carbon Tracker, an independent financial think tank,                        USD 579 billion11. But just de-carbonizing one element of
   calculated that the renewable energy opportunity could                      the mix – supply-side energy systems – means that level of
   reach USD 1 trillion per annum 8.                                           investment needs to increase five-fold.

2. CPI estimates suggest that just to transition the supply-side               On the plus side, climate finance flows are rising. Average
   energy systems could take an annual investment of                           annual tracked climate finance flows over the period
   USD 1.6 trillion – USD 3.8 trillion between 2016 and 2050 9.                2017/2018, represented an increase of USD 116 billion (25%)
                                                                               from 2015/2016. The rise reflected steady increases in
3. The International Energy Agency (IEA) Sustainable                           financing across nearly all investor types12.
   Development Scenario points to an investment of
   USD 1.6 trillion every year from 2025 to 203010.

                                                                                               25%
                                                                                                Compared to 2015/16, average annual
                                                                                                tracked climate finance flows over the
                                                                                                period 2017/2018 were up by 25%.

8		https://www.unpri.org/inevitable-policy-response/the-trillion-dollar-energy-windfall/4784.article
9		https://climatepolicyinitiative.org/publication/ global-climate-finance-2019/
10 https://www.iea.org/reports/world-energy-model/sustainable-development-scenario
11 https://climatepolicyinitiative.org/publication/ global-climate-finance-2019/
12 https://climatepolicyinitiative.org/publication/ global-climate-finance-2019/

12
The great divide

In-need sectors project strong returns. But still                                In 2019, UBS concluded an eighteen-month research project,
investment levels are falling short                                              ESG: Do you or Don’t you? with Responsible Investor
The fact that a climate finance gap exists seems paradoxical.                    which surveyed institutional investors globally. One of the
In 2019, a comprehensive report from consultants Mercer                          most revealing findings was the importance placed on
modelled a wide range of outcomes arising from different                         environmental factors: the majority of European respondents
climate scenarios. They concluded that investing for a 2°C                       believed that within the next five years, these could outstrip
scenario is both an imperative and an opportunity13:                             financial factors in terms of materiality for their investments.

– An imperative, since, for nearly all asset classes, regions and                A similar picture emerges among many wealth management
  timeframes, a 2°C scenario leads to enhanced projected                         clients. The UBS 2019 Global Family Office report revealed
  returns versus 3°C or 4°C and therefore a better outcome                       that among a range of investment trends, climate
  for investors                                                                  change is the single most supported cause, with 62% of
                                                                                 respondents reporting that they have invested in one or
– An opportunity, because although incumbent industries can                      more of the following: carbon footprint management,
  suffer losses in a 2°C scenario, a low-carbon transition still                 wind or solar energy.
  offers many notable investment opportunities.
                                                                                 In the next chapter, we explore some of the investment
Unsurprisingly, Mercer found that a 2°C scenario would lead                      barriers which are contributing to this climate finance gap.
to positive returns for renewable energy investment, and
negative returns for coal.

13   Source: Mercer “Investing in a time of climate change – the sequel”, 2019

                                                                                                                                                13
Climate change remains the most serious threat to the Great Barrier Reef. Sea temperatures are
on the rise and this trend is expected to continue, leading to an increased risk of mass coral
bleaching; gradual ocean acidification will increasingly restrict coral growth and survival.

       14
The
barriers to
investment
What climate challenges do investors face?

Where’s the risk?
The starting point for any investor thinking about climate change is the risk landscape.
Broadly speaking, climate risks are thought of as either:

– Physical: the damage to business continuity, asset values and productivity caused
  by rising temperatures and the associated effects
– Transitional: the costs incurred in transitioning to a lower-carbon economy

                                                                                       15
The barriers to investment

Climate-related risks

                                         Physical risks                                                        Transition-related risks

                         Acute                     Chronic                    Policy and                 Technology               Market                 Reputation
                         risks                     risks                      legal risks                risks                    risks                  risks

Examples of                Increased risk of       Changes in climate          Imposition of             Investment and           Uncertainty            Stigmatization of
potential risks            extreme weather         and landscape,              mitigation policies       transition costs         regarding consumer     industry
                           events                  e.g. coastal areas          or regulation             to a low-carbon          behavior, market
                                                   or rain forests             and exposure to           technology               signals and supply     Changes in consumer
                                                                               litigation                                         chain                  preferences and
                                                                                                         Uncertainty of                                  stakeholder
                                                                                                         investment decisions                            expectations

Examples of                Reduced revenue from negative impacts on            Increase in operating     Value loss of existing   Reduced demand         Reduced revenue
possible financial         production facilities, sales and workforce          and/or litigation costs   assets                                          due to decrease in
implications                                                                                                                      Increased costs from   demand, production,
                           Increased operating, capital and insurance          Forced capital            Reduced demand for       unexpected market      capital availability
                           costs, as well as asset depreciation due            depreciation due          products and services    changes in supply      and employee
                           to damages                                          to policies                                        chains                 attractiveness
                                                                                                         Costs of developing
                                                                                                         and procuring new
                                                                                                         technology

Source: Adapted and simplified from Taskforce on Climate-related Financial Disclosure (2017a).

16
The barriers to investment

                                                                                              All institutional investors have an
                                                                                              over-riding fiduciary duty to their
                                                                                              beneficiaries: ensuring they promote
                                                                                              and safeguard their interests.

2100 warming predictions

                                                  200

                                                  150
Global greenhouse gas emissions – GtC02e / year

                                                                                                                                          Baseline 4.1–4.8˚C

                                                  100

                                                   50
                                                                                                                                          Current policies 3.0–3.4˚C
                                                                                                                                          Optimistic policies 2.9˚C
                                                         Historical                                                                       Pledges and targets 2.6–2.9˚C

                                                    0                                                                                     2.0˚C consistent
                                                                                                                                          1.5˚C consistent

                                                  -50

                                                        '90           '00   '10   '20   '30    '40   '50   '60   '70   '80   '90   2100

Source: Climate Action Tracker, September 2019.

                                                                                                                                                                          17
The barriers to investment

                                                            According to the World Meteorological
                                                            Association, the four years to 2018
                                                            were the hottest on record, due to
                                                            increasing greenhouse gas emissions .                                                                        14

The effects of global warming are already quite clear. According to the World Meteorological Association, the four years to
2018 were the hottest on record, due to increasing greenhouse gas emissions (GHGs)14. After adjusting for inflation, annual
insured losses from catastrophic climate-related events have multiplied by a factor of 20 over the past 30 years, reaching an
annual average of USD 65 billion this decade15.

Global occurrences of extreme weather events

                              Floods                                                                               Droughts
                      3,000                                                                                  600
                                                                                        Number of droughts
Number of floods

                      2,000                                                                                  400

                      1,000                                                                                  200

                         0                                                                                     0
                                  1950–1966    1967–1983   1984–2000   2001–2018                                              1950–1983               1984–2018

                              Wildfires                                                                            Extreme temperature events
                       400                                                                                   500

                                                                                                             400
                                                                                        Number of events
Number of wildfires

                       300
                                                                                                             300
                       200
                                                                                                             200
                       100
                                                                                                             100

                         0                                                                                     0
                                          1950–1983             1984–2018                                              1950–1972          1973–1995          1996–2018

Source: The New Climate Economy, 2018.

14           World Meteorological Association: The State of the Global Climate in 2018, pub. March 2019.
15           Swiss Re Institute: Natural catastrophes and man-made disasters in 2018: “secondary” perils on the frontline February 2019.

18
The barriers to investment

The future of climate is hard to predict, especially when it comes to risk.

                             We think we’re facing four main challenges that are creating barriers for investors:

1      Regulatory
                                   2      Investment
                                                                       3       Data
                                                                                                           4        Practical constraints
       dynamics                           horizons                             imperfections                        on financial innovation

1. Regulatory dynamics                                                  measures. All of them are loosely working toward meeting the
                                                                        Paris goals, but they’re aimed at different areas of the financial
It’s hard to manage global investments when countries                   markets and carry varying levels of ambition. In particular,
are setting very different climate change regulations,                  the absence of regulation in the US represents a significant
and at varying pace                                                     weakness in the web of climate-finance-relevant regulation.
All institutional investors have an overriding fiduciary duty to
their beneficiaries: ensuring they promote and safeguard their          Particularly for large-scale institutional investors this presents
interests. Complying with relevant regulation is fundamental            a problem. They’re global in their approach, therefore
but can be hard to achieve when regulatory frameworks are in            different regulatory regimes, in different regions, all moving
a state of flux.                                                        at different speeds, can be hard to manage, especially when
                                                                        trying to develop scalable financial solutions that can channel
Since the Paris Agreement, investors’ responsibilities to               capital toward addressing climate change.
combat climate change have increased. However, looking at
the global regulatory landscape, we see a patchwork of

                                                                                                                                        19
Recent regulatory examples                                                     covered investment advice, independent low-carbon
It’s generally accepted that Northern Europe is the most                       indices and a green ‘taxonomy’. This is a list of business
advanced in terms of climate-related regulatory frameworks,                    activities considered in line with the transition toward a
but that’s not to say concerns don’t exist around the                          low-carbon economy. The taxonomy will also act as a
effectiveness, consistency and speed of implementation.                        disclosure framework. Discussions currently underway
                                                                               include a requirement for institutions selling ‘green’ labeled
– France: The first to legislate in 2015 as part of its “energy                funds or other investment products in the EU to disclose
  transition for green growth” law. France’s comply-or-explain                 how those products align with the taxonomy.
  green finance order requires investors operating in France
  to report on integrating environmental, social and                           The recommendations are at the final stages of political
  governance (ESG) factors into their investment processes,                    negotiations but several sticking points still exist. Although
  identify the greenhouse gas emissions of their assets                        the Action Plan has advanced the agenda, critics have
  and show how they’re contributing toward financing a                         suggested it remains too vague in its objectives. Many
  low-carbon economy.                                                          experts are still unsure how its proposals can be enacted.

– The European Union: In March 2018, the European                           Beyond the EU, Canada and China have both passed legisla-
  Commission (EC) adopted a Sustainable Finance Action Plan                 tion designed to improve transparency around ESG consider-
  (the “Action Plan”)16 as part of its strategy to integrate ESG            ations. Their efforts target investors and companies. Globally,
  considerations in its financial industry policy framework                 the EU formed the International Platform on Sustainable
  and mobilize finance for sustainable growth.                              Finance (IPSF) with China, India, Argentina, Chile, Canada,
                                                                            Kenya and Morocco in October 2019. Collectively, they
     The Action Plan’s focus is a set of recommendations for                account for nearly half the world’s GDP and carbon emissions.
     greater transparency. Last year the EU updated its non-                They want to export a green taxonomy to other regions and
     binding guidelines on non-financial reporting by companies             countries, thereby harmonizing the rules on what constitutes
     to include climate-related reporting. The guidelines also              sustainable, or “green”, investment. As with similar frame-
                                                                            works, the reception has been mixed.

16   https://ec.europa.eu/info/business-economy-euro/banking-and-finance/green-finance_en

20
The barriers to investment

The Federal Reserve Board and the Federal Reserve Bank                         By contrast, the US Department of Labor issued new
of San Francisco have each recently published research                         guidance in 2018. It targeted private sector employee benefit
highlighting the financial risks of climate change.17 But right                plans and the integration of ESG factors in the investment
now the appetite for regulation at a national level seems low.                 process as it relates to their fiduciary duty. The guidance
                                                                               acknowledged that evaluating ESG factors can form one
The views of fiduciary duty are changing when it comes                         aspect of a fiduciary’s duty, but reaffirmed the need to
to climate change                                                              prioritize the economic interests of beneficiaries19.
Regulators are grappling with the change in fiduciary thinking
needed to bring a long-term risk into the short-to-medium                      This illustrates the scale of the dilemma facing global
term investment lenses of pension funds and asset managers.                    investors – actions required in one jurisdiction can appear
As climate risks start to impact the wider economy,                            to conflict with actions required in another.
acceptance is growing that investment managers need to
incorporate those risks within their investment processes.                     Recognizing this uncertainty, The Principles for Responsible
                                                                               Investment (PRI), the United Nations Environment Programme
The UK introduced new ESG regulations in 2019 requiring                        Finance Initiative (UNEP FI) and The Generation Foundation,
pension scheme trustees to update their statements of                          have just finalized a three-year project, Fiduciary Duty in
investment principles and show how they’re integrating ESG                     the 21st Century. One conclusion was that fiduciary duty
factors into their long-term strategic investment risks. Its                   includes the incorporation of ESG issues into investment
newly-published Green Finance Strategy18 clearly expects                       analysis and decision-making processes, consistent with
greater climate-related disclosure by large asset owners by                    investment time horizons20.
2022, in line with the TCFD recommendations.

17 https://www.frbsf.org/economic-research/publications/economic-letter/2019/march/climate-change-and-federal-reserve/ and
   https://www.federalreserve.gov/newsevents/speech/brainard20191108a.htm
18 https://www.gov.uk/government/publications/green-finance-strategy
19 https://corpgov.law.harvard.edu/2018/05/02/department-of-labor-cautionary-tone-on-esg-related-activities/
20 Fiduciary Duty in the 21st Century, PRI, 2019 https://www.unpri.org/fiduciary-duty-in-the-21st-century-final-report/4998.article

                                                                                                                                             21
Bank of England smoothing the transition
to a low-carbon economy
By Huw van Steenis
Senior Adviser to the CEO and Chair of the Sustainable Finance Committee, UBS AG
Former senior adviser to Governor Carney on the Future of Finance

The transition to a low-carbon economy poses both risks, and opportunities, for the
economy and the financial sector. Investors, lenders and insurers don’t yet have a
clear view of which companies will struggle, endure or prosper as the environment
changes, regulations evolve, new technologies emerge and customer behavior shifts.
Without this information, financial markets can’t price climate-related risks and
opportunities effectively.
Moreover, the transition to a low-carbon         managers, pension funds, insurers, credit          where no further climate action is taken, a
economy will require large-scale reallocations   rating agencies, accounting firms and              scenario where early policy action delivers an
of capital and investments in infrastructure −   shareholder advisory services.                     orderly transition to the targets set in Paris,
on some estimates more than USD 100 trillion                                                        and a third where late policy action leads
globally over the next decade.                   So far there has been enormous success             to a disorderly and disruptive transition.
                                                 through voluntary reporting. In the past year,
It was with this context in mind that Governor   almost 200 Japanese firms have joined the          This way the Bank can help understand
Carney asked me to explore how the Bank          TCFD, bringing Japan to the top of the TCFD        if firms are “transition ready” for a lower-
of England (the Bank) could “promote the         league table .22
                                                                                                    carbon economy. The exercise should be
smooth transition to a low-carbon economy”                                                          likely to spur firms to develop additional risk
                                 21
in the Future of Finance report . Governor       But there are stragglers. That's why I agree       management techniques for climate risks.
Carney, both through his leadership of the       with Sir Chris Hohn, Managing Partner of The
Financial Services Board and at the Bank of      Children's Investment Fund: all companies          The overall results of the sector's resilience to
England, had catalyzed a number of world         should look to disclose on a TCFD basis.           climate-related risks will be published and are
leading initiatives.                             Hence I recommended the Bank should                highly likely to impact how banks and insurers
                                                 champion mainstream financial reporting in         think about the cost of capital to different
It is worth understanding the Bank’s ideas,      the next few years, as well as enhanced            projects in future − which will in turn be a
as these are being rapidly copied by other       disclosures across the real estate sector.         factor that investors will likely need to weigh
central banks and policy makers, and             Consideration of the appropriate base line         up over the coming years23.
are likely to shape market and investment        and disclosure of firms’ strategies will be the
opportunities for investors.                     priority. The Bank plans to lead by example        Since these measures have been announced
                                                 and become the first central bank to publish       several other central banks have said they are
Mainstream climate change related                its exposure on a TCFD basis.                      looking to copy them or team up to build
disclosures                                                                                         momentum. I expect 2020 will be pivotal in
The Task Force on Climate-related Financial      Embed climate risk management                      terms of many other central banks launching
Disclosures (TCFD) has made important            The financial sector can play a decisive role in   similar initiatives − under the Network for
progress in creating a standard for decision     mobilizing capital − if it understands the risks   Greening the Financial System.
useful climate-related information. For me       and develops the tools to manage them.
it is increasingly the gold standard upon        TCFD is foundational but additional risk           Bottom line
which so much is being built, and which all      management tools and practices need to be          The global energy sector and numerous
investors need to understand to make better      developed. According to a recent survey from       others are being reshaped as governments
informed decisions.                              the Bank of England, almost three-quarters         look to shape movement to a lower-carbon
                                                 of UK banks are starting to treat climate          system. For long-term investors, these
Catalyzed by the G20 and fashioned by the        risks like other financial risks.                  present both investment risks and
private sector, the TCFD has established a                                                          opportunities. How central bank actions may
comprehensive and flexible framework for         So the Bank intends to undertake a ground-         influence the cost and availability of capital
corporate disclosure of climate-related risks    breaking exploratory stress test of the largest    will be one critical factor to understand
and opportunities. Current supporters control    UK banks and insurers for climate risks in         in the next few years as investors look to
balance sheets totaling USD 120 trillion. They   2021. The firms will be asked to model their       make their portfolios more resilient to
include the world’s top banks, asset             exposures to three climate scenarios: the          climate change risk.
                                                 catastrophic business-as-usual scenario
                                                                                                    Huw van Steenis

21 https://www.bankofengland.co.uk/-/media/boe/files/report/2019/future-of-finance-report.pdf?la=en&hash=59CEFAEF01C71AA551E7182262E-
   933A699E952FC
22 https://www.bankofengland.co.uk/-/media/boe/files/speech/2019/tcfd-strengthening-the-foundations-of-sustainable-finance-speech-by-mark-carney.

   pdf?la=en&hash=D28F6D67BC4B97DDCCDE91AF8111283A39950563
23 https://www.bankofengland.co.uk/research/future-finance
The barriers to investment

2. Investment horizons
Investment frameworks don’t currently address                                 On the other hand, even though institutional investors often
long-term climate change trends                                               carry obligations which extend across generations, evidence
Thinking about climate change in terms of time frame raises                   suggests some equity managers hold assets for an average of
two clear challenges. The first relates to the fact that while                just 1.7 years25. That offers analysts little incentive to extend
climate change is generally accepted to be a long-term                        their projections.
risk, the actions needed to tackle it are short-term. For
investors this poses a fundamental problem. Put simply,                        The second challenge relates to the relative infancy of
existing short-term investment frameworks aren’t designed                      technologies being designed to capture climate change. Many
to capture long-term risks.                                                    are at a very early stage of development with a high degree
                                                                               of uncertainty around future positive cash flows, which can
On the one hand, many analysts’ investment targets only                        prove a disincentive for many investors.
extend across one to three years, often based on historic
data. A lack of meaningful forward-looking company data                        Until this self-perpetuating loop is addressed the danger
is frequently blamed for compounding this short-term                           remains that climate risk cannot be accurately priced
analysis24 – something we discuss later in this paper.                         and effectively captured within the investment process –
Consequently, only risks that are expected to materialize                      a dilemma famously summed up by Mark Carney,
within that one to three year timeframe are likely to be                       Governor of the Bank of England, in his 2015 “Tragedy
assessed.                                                                      of the Horizons” speech26.

24 All swans are black in the dark. How the short-term focus of financial analysis does not shed light on long-term risks. The Generation Foundation
   February 2017, http://www.tragedyofthehorizon.com/.
25 All swans are black in the dark. How the short-term focus of financial analysis does not shed light on long-term risks. The Generation Foundation

   February 2017, http://www.tragedyofthehorizon.com/.
26 Carney, M. 2015. Breaking the tragedy of the horizon—Climate change and financial stability. Accessed October 16, 2017.

   http://www.bankofengland.co.uk/ publications/Documents/speeches/2015/speech844.pdf.

24
The barriers to investment

3. Data imperfections
It can be hard to assess investments because climate               Investors have found it hard to accurately compare different
data is often complex, incomplete and fragmented                   sustainable investment instruments and single out the one
Private clients and institutional investors are both challenged    best matched to their needs. And where sustainability
by the lack of standardized sustainability data. Ultimately, any   measurement is more complex (such as assessing climate
framework is only as good as its data inputs. But, a lack of       change risk and carbon footprints), the problem of data
well-founded quantitative risk metrics and forward-looking         comparability is even harder for investors to overcome.
indicators from companies, makes it difficult to generate
meaningful outputs.

                                             Private clients and institutional
                                             investors are both challenged
                                             by the lack of standardized
                                             sustainability data.

                                                                                                                                  25
The barriers to investment

To mitigate this, we have developed a multi-vendor database                              Just 55% of companies in the MSCI ACWI index currently
for sustainable investment data, aggregating and filtering                               report on CO2 data27.
information to provide greater comparability between
sectors and regions. At the top of the list come Food                                    According to findings from the Corporate Reporting Dialogue
and Beverage, as well as Health Care firms. Laggards,                                    (CRD)28, most users of financial statements believe existing
unsurprisingly, include Infrastructure firms and Extractive                              disclosures lack information across all of the TCFD recommen-
and Minerals Processing companies.                                                       dations. The Bank of England commented that the growth in
                                                                                         potentially piecemeal disclosure schemes may slow adoption29.
Data around climate-related risk in particular is far from                               Additional information about frameworks and standards, and
perfect. We’ve already seen how incomplete and inconsistent                              better alignment between them, could help investors make
data sets can represent a major barrier for investors.                                   more useful investment decisions.

European companies are climate leaders, while Middle Eastern companies lag

                Climate leaders
8

6

4

2

0
       Western Europe        North America         Asia Pacific            Africa           Latin America        Asia ex-Japan    Eastern Europe   Middle East

Source: UBS, SASB, Sustainalytics, Trucost, CDP, 2019. Notes: MSCI ACWI constituents, weighted by share in index, SICS Sectors.

27 MSCI: Carbon Emissions Estimation. November 2019.
28 Corporate Reporting Dialogue “Driving Alignment in Climate-related Reporting”, 2019.
29 Future of Finance: Review on the outlook for the UK financial system (June 2019).

26
The barriers to investment

Sectoral variations: thinking about the impact of climate          For example, business model risks could emerge for fossil fuel
on different businesses                                            producers (coal, oil and gas exploration and production),
Another way that investors can think about the impact of           agricultural products, electric utilities, home builders, waste
climate change is to look at the ways it could affect different    management and water utilities.
parts of the investment valuation. The Sustainability Accounting
Standards Board’s (SASB’s) Materiality Map® can be helpful as      Even with the benefit of such frameworks and guidance,
it also recognizes how adaptable different sectors are likely to   investors can still find it challenging to include such consider-
be. It categorizes risks across:                                   ations within their asset allocation process. Our Investment
                                                                   Solutions team is producing a white paper on the practical
–   Business models                                                aspects of strategic asset allocation within an ESG framework.
–   Product design and lifecycle management                        It will investigate the implications of factors such as climate
–   Transition risk measures                                       change on investment returns. Are the expected returns of
–   Physical risk measures                                         asset classes with ESG overlays different from those of the
–   Risk metrics                                                   comparable traditional asset classes; what other risks and
–   Forward-looking indicators                                     opportunities could an ESG focus highlight?

                                                                                                                                  27
The barriers to investment

4. Practical constraints on financial
   innovation
Currently, larger institutional investors wanting to invest in             commonly awarded by governments, aren’t always aligned.
clean energy are frustrated by a lack of financial products                Other factors, like a lack of qualified labor, shortages of
suited to their asset allocation approach. In general, they’d              available land and excessive bureaucracy compound the
rather allocate larger sums per transaction than the typical               problem further still.
clean energy investment opportunity presently allows.
Solving that conundrum means developing more low-                          In terms of the regional need to abate carbon emissions,
carbon opportunities as well as a broader set of capital                   emerging markets represent the largest share of projected
market instruments.                                                        emissions growth31. However, levels of project-specific risks
                                                                           in these locations, and the need to manage those risks,
New wind and solar projects have become more cost-                         can be magnified in ways that may exceed investors’
competitive than coal in most of the world, over quite a short             risk tolerance.
period of time. Yet despite this investment model, renewables
still represent a modest share of global energy supply – in                Other barriers to structuring of appropriate investable
2018, only 6% could be attributed to wind and solar30.                     instruments can be:

Practical barriers to scaling-up include the absence of local              – Decision-useful data: even if it’s available, it can
legislative and regulatory frameworks. The timelines of                      be difficult to integrate and standardize across risk
corporate finance agreements put in place to fund new energy                 management, strategy, and client engagement functions
construction projects, and the 10-20 year concession contracts             – Methodologies: they don’t always resolve fundamental
                                                                             questions such as how to attribute emissions in financial
                                                                             portfolios or how to set emissions reduction pathways
                                                                             for sectors

30   IRENA, Renewable Energy Statistics 2018, International Renewable Energy Agency, 2018.
31   Climate Investment Opportunities in Emerging Markets An IFC Analysis 2016 https://www.ifc.org/wps/wcm/connect/59260145-ec2e-40de-97e6-
     3aa78b82b3c9/3503-IFC-Climate_Investment_Opportunity-Report-Dec-FINAL.pdf?MOD=AJPERES&CVID=lBLd6Xq

28
Our aim is to be a
leading financial
provider in enabling
investors to mobilize
private and institutional
capital targeting climate
change mitigation
and adaptation while
supporting the
transition to a low-
carbon economy.
Current practice

                   The
                   investors‘
                   perspective
                   How are investors tackling climate change?

     30
Rooftop gardens are a way of bringing greenery into a sterile space. They can be places
where plants and vegetables can be grown to support a sustainable lifestyle.

Given the barriers we’ve described, how are investors responding? Specifically, how
is the impact of climate change already playing out, and what are institutional and
private wealth investors doing to allocate their capital toward the transition to a
lower-carbon future?
We take a closer look at five distinct investor types and their current responses to the challenges of climate change:

  Pension                         Central                         Sovereign               Private                Philanthropy
  funds                           banks                           wealth funds            wealth investors       solutions

                                                                                                                                31
Current practice: The investor’s perspective

Pension funds

Many pension funds and asset owners recognize climate change as one of the largest
systemic risks in their investment portfolios. But the lack of formalized methodologies
means integrating climate risk into the investment process can be challenging.

The following investor snapshots               focusing on climate change. To comply       HESTA (Australia) The fund’s Climate
illustrate how varied current pension          with local regulation, it will publish a    Change Policy objectives are designed
approaches are.                                TCFD aligned climate-related risk report    to protect it from assets believed to be
                                               in January 2020. It is working on several   at the highest risk of becoming stranded
CALPERS (US) the Californian State             quantitative models designed to             assets, notably fossil fuels. Climate
retirement plan, is completing a carbon        improve the analysis and understanding      change risks and opportunities are
foot-printing of its public and private        of how and where climate change could       embedded within its investment and
asset classes. CALPERS has a substantial       impact global capital markets. CALPERS      decision-making process. The fund
engagement and advocacy program                is one of the founders and steering         regards itself as a universal and long-
                                               committee members of the Climate            term owner. It does not support an
                                               Action 100+ engagement program.             exclusion or divestment approach based
                                                                                           on climate change risks.

32
Current practice: The investor’s perspective

Central banks

The climate concerns of central banks are similar to those of other large-scale
institutional investors, but their perspective is unique.

Climate change could pose a risk to            Several climate-related policy initiatives   The NGFS encourages its members
economic and inflation outlooks: both          exist. The most important is the Central     to lead by example, urging them to
core central bank responsibilities. Those      Banks and Supervisors Network for            integrate climate-related criteria in their
risks could be the physical impact of          Greening the Financial System (NGFS).        own operations.
extreme weather events, or the
economic disruption that transitioning         Member institutions account for almost
toward a low-carbon business model             half of global GDP and two-thirds of
might cause in the financial and               systemically important banks and
corporate sector.                              insurers, currently not including the US.
                                               The focus is two-fold:

                                               – Supervisory and macro-prudential
                                                 tasks relating to financial and systemic
                                                 risk caused by climate change
                                               – Better disclosure standards

                                                                                                                                     33
Current practice: The investor’s perspective

Sovereign wealth funds

Collectively, sovereign institutions manage approximately USD 20 trillion. Their fiduciary
duty covers many stakeholders, including the general public. Not surprisingly, because
their activities are often closely scrutinized many are starting to incorporate climate risk
into their mandates and investment frameworks.

The clearest argument for integrating          national wealth is invested over the         GPIF (Japan) the world’s largest pension
ESG and the materiality of climate risks       long-term and diversified across             fund recently carried out a study on
lies with the commodity-based sover-           investment strategies grounded in            the impact of climate change on its
eign wealth funds, which account for           sound economic, social, environmental        assets, which it published in September
roughly half of all sovereign assets           and governance factors.                      2019 – Analysis of Climate Change
globally. A rational economic case could                                                    Impacts on Portfolios. It also published
be made for these countries to extract         Norges and Japan’s Government                climate-related information for its
as many resources as possible from the         Pension Investment Fund (GPIF) each          first ESG report, structured in line with
ground while global demand remains             illustrate ways that sovereign wealth        the recommendations of the TCFD.
solid. But the global need to transition       funds are addressing climate change.         In October 2019, GPIF announced it
to a low-carbon economy poses a                                                             would join the Climate Action 100+
fundamental challenge that will                Norges Bank Investment                       engagement program.
determine their future prosperity. This        Management (Norway) manages the
is where the principles of sustainable         assets of the Norwegian Government
investing meet prudent, long-term risk         Pension Fund Global (GPFG). Since 2014
management: both aim to ensure                 it has clearly set out its expectations of
                                               the ways in which companies should
                                               approach the risks and opportunities
                                               associated with climate change, as well
                                               as the role of fossil fuel investments
                                               within its fund.

34
Current practice: The investor’s perspective

Private wealth investors

Private clients undoubtedly regard climate change as important. But our own research
and experience tell us it is one among a number of sustainability topics which matter
to them. They have deeply personal views on what is sustainable and their own
sustainability interests vary considerably.

A UBS Investor Watch Survey of over               sustainable investment advice based on                  of sustainable investment content is
5,000 high-net-worth investors                    each private client’s individual affinities.            important. A recent private client survey
revealed fifty-eight percent of ultra             We have enhanced transparency on six                    that we conducted found that private
high net worth investors think that               key sustainability topics to power this                 wealth clients often have divergent
sustainable investing will be the norm            initiative. Attracting more than USD                    views of what matters most to them,
within 10 years. In aggregate, our                800m of client assets, the pilot has                    what they deem to be a sustainable
data shows that they’re most                      proved a major success that justifies                   business activity, and that they often
interested in tackling environmental              the rollout of a full and permanent                     hold differing personal values. For
topics, including water, pollution and            personalized sustainability investment                  example, while 45% of surveyed clients
waste, and climate change32.                      advisory offering.                                      express a high affinity to ‘people’
                                                                                                          topics, not every client agrees. 38%
Family offices reflected that senti-              The first phase of its launch across our                expressed a low interest in aligning
ment. 62% believe most of their                   global wealth management business                       their investments to this topic.
peers will invest sustainably by 2022.            will begin in early 2020. Personalization
They expressed a level of frustration
though with the challenge of
accessing offerings with direct                   Private wealth clients have diverging views on what matters to them
impact. Like institutional investors,
                                                           Percent of clients expressing high affinity     Percent of clients expressing low affinity
the lack of scalable solutions is a
                                                  80%
problem. According to the 2019
UBS / Campden Wealth Global Family
Office survey, 36% of respondents                  60
say there are “not enough opportuni-
ties to invest in green technology.”
                                                   40
In its 2019 WEF Whitepaper,
Awareness, simplification, and
                                                   20
contribution33, UBS announced a pilot
program to deliver personalized
                                                    0
                                                              Climate Change                     Water          Product and services                    People

                                                  Source: UBS Global Wealth Management, Client Based Insights 2019.

32   https://www.ubs.com/global/en/wealth-management/our-approach/investor-watch/2018/return-on-values.html
33   https://www.ubs.com/microsites/wma/insights/en/investing/2019/tackling-worlds-urgent-challenges.html

                                                                                                                                                                 35
Current practice: The investor’s perspective

Philanthropy solutions

By developing three principles for effective climate philanthropy, we can help clients
use their capital to address climate change

Clients don’t just want investment             where resources can do the most                the all-important ways to remove
solutions, they’re eager to use risk           good, our clients can give with more           carbon dioxide from the atmosphere:
capital to address climate change              confidence and make their philanthropic        carbon capture and carbon dioxide
through their philanthropic efforts. UBS       journey more rewarding.                        removal.
Optimus Foundation and the Climate
Leadership Initiative (CLI) have devel-        Several sectors of the economy provide         The scope and scale of impact for each
oped three principles for effective            feasible opportunities for philanthropy        of these sectors vary in every region of
climate philanthropy. In fact, CLI was         to act as a vital catalyst to accelerate the   the world. It’s essential to consider local
created by six of the top climate donors       transitions needed to tackle climate           contexts, priorities and opportunities to
this year with the goal of making it           change. The key sectors are:                   strategically fund projects that stand to
easier for new philanthropists to learn,                                                      drive the most change. In China and
become connected to like-minded                –   Pollution free electricity/energy          India, for example, it’s critical to
people and experts and collectively            –   Transport                                  transition to clean fuels and power to
tackle the issue.                              –   Buildings                                  meet rising energy demands. In Brazil
                                               –   Industry/production                        and Indonesia, forest protection requires
Understanding how experts view                 –   Food/farming                               urgent philanthropic support and
opportunities to solve the climate crisis      –   Natural landscapes/forests                 resources. And in the global effort to
is helpful as a frame for new donors.                                                         phase out coal, Southeast Asia is the last
They generally think of solutions              Necessary changes include transitioning        frontier for coal power plant demand
through the lens of three ‘dials’ to turn:     to renewable energy sources; investing         and development.
sector, geographic region and enabling         in regenerative farming practices to
levers. By understanding how and               ensure the global demand for food is
                                               met sustainably; protecting forests and
                                               grasslands; stopping powerful methane
                                               from escaping into the atmosphere; and

36
Current practice: The investor’s perspective

Regions: Seven are key to the solutions

    Fossil transition and removal

    Pollution-free electricity

    Better buildings
                                                                                           EU
    Clean production                                                                                    China
                                                                                           8%
                                                                                                        19%
    Sustainable food and farming

    Landscape protection
                                                   USA
    Transportation revolution                      11%

                                                                                                India
                                                                                                13%

                                                                                                                SE Asia
                                                                           Africa
                                                                                                                 5%
                                    Brazil                                 11%
                                     4%

Source: CWF Analysis using Global Change Assessment Model (GCAM) v. 5.1.3, October 2019.

                                                                                                                          37
Salt marshes are coastal wetlands that are flooded and drained by salt water brought in
by the tides. A healthy salt marsh is a complex ecosystem delicately balanced between
the marine and terrestrial environments.

       38
Are you
climate
aware?
A climate-smart framework for investors

An investor-oriented approach
We’ve seen the extent of the challenges faced by all investors. How do they position
their investments or capital to make the transition toward a lower-carbon future?
Given the inherent uncertainties of climate change, can they be sure they’ve properly
captured the investment risks and opportunities? And how do they adjust to an
inconsistent and fluid regulatory environment?

                                                                                        39
Are you climate aware?

While a lot is being done to invest for a lower-carbon world,      Our methodology contains three key elements:
investors are signaling the need to be more ambitious and
move faster. Our own research has shown that allocators want       – Portfolio mitigation: Lowering investment exposures
to use their capital in a climate-smart way and help close the       to carbon risks
climate gap.                                                       – Portfolio adaptation: Increasing investment exposures
                                                                     to climate-related innovation and solutions
De-carbonizing existing portfolios won’t be enough. Waiting        – Portfolio transition: Aligning investments to the
for data to be perfected or legislation to be put in place only      requirements of a lower-carbon economy
prolongs the delay, while placing faith in the ingenuity needed
to support economic growth with net negative CO2 emissions         It is a pragmatic, flexible, investor-led approach. Minimizing
could prove misplaced.                                             allocations to companies most negatively affected by climate
                                                                   change should help to mitigate the downside risk, while
Investors need actionable tools and techniques: methodolo-         increasing exposure to companies with climate-smart business
gies that guide them in a changing and uncertain world,            models and offerings may maximize the upside opportunity.
providing greater certainties so they can allocate their capital   By balancing each of these three elements investors can:
in ways that drive the low-carbon transition. And most
importantly, they need to be able to act today, not wait for       – Achieve a holistic, forward-looking approach to tackling
tomorrow.                                                            the uncertainties and challenges of climate change
                                                                   – Adjust one or more of the individual elements as
We recognize these shortcomings which is why we are                  circumstances change
proposing a methodology to help investors become fully             – Have an opportunity to make better informed investment
‘climate aware’. Moving away from a dependence on                    decisions and use their weight of capital to influence
backward-looking data and toward a forward-looking                   change
model can help them to position their portfolio for a
climate-smart future.                                              At any given point in time, investors can dial up or dial down
                                                                   one or all of the three elements, to better balance their
                                                                   climate risks and objectives.

                                                                   A program of active engagement underpins the methodology,
                                                                   which is essential. It looks to provide deeper insights to the
                                                                   actions and progress which companies are making toward a

40
Are you climate aware?

climate-smart future. Those insights mean that investors                               We call this combination of portfolio adjustment and active
can directly link the adjustments they make to investments                             engagement the ‘Climate Aware’ framework. It can serve as
in their portfolios to actions that investee companies are                             a blueprint for investors to address the historic challenges
taking to address climate change. Through this combination                             presented by climate change.
of portfolio strategy and collaborative engagement,
investors may have a significant impact on efforts to tackle
climate change.

A climate aware framework for investors

                                                                                       Portfolio adaptation
                                                                                       Increasing investment exposures
                                                                                       to climate-related innovation and solutions

                                                                           A balanced
                                                                            approach
                                                                         We need a balanced
                  Portfolio mitigation                                   approach to channel
                  Lowering investment                                   capital toward a lower
                  exposures to carbon risks                                 carbon future

                                                                                                               Portfolio transition
                                                                                                               Aligning portfolios to your
                                                                                                               chosen climate glidepath

Source: UBS Asset Management. When we named the characteristics we deliberately borrowed from the scientific taxonomy of the low-carbon transition, as we believe these
terms are particularly relevant to our methodology.

                                                                                                                                                                          41
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